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GALUSKA v. C.I.R.

No. 92-3591.

5 F.3d 195 (1993)

Richard J. GALUSKA, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided September 9, 1993.

Rehearing and Suggestion for Rehearing Denied November 10, 1993.

Attorney(s) appearing for the Case

David M. Kirsch (argued), San Jose, CA, for petitioner-appellant.

Richard Farber, Gary R. Allen, Regina S. Moriarty (argued), Dept. of Justice, Tax Div., Appellate Section, Washington, DC, for respondent-appellee.

Before CUMMINGS and RIPPLE, Circuit Judges, and WILLIAMS, Senior District Judge.

Rehearing and Suggestion for Rehearing In Banc Denied November 10, 1993.

CUMMINGS, Circuit Judge.

In June 1992 taxpayer Richard J. Galuska filed a petition in the Tax Court seeking a refund for overpayment of income tax for 1986. The court held that no refund was allowable, resulting in this appeal. We affirm.

Facts

On April 15, 1987, Galuska filed an application for extension of time to file his income tax return for 1986 until August 15...

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